2026 State Implementation Plan Revisions for the California Extreme Ozone Nonattainment Areas

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Comment From: Fresno Council of Governments (Robert Phipps)

7/23/26 @ 3:29 PM Day of Board Meeting Form Letter 1

Madam Chair and Board members:

Thank you for the opportunity to speak. My name is Robert Phipps, executive director with Fresno Council of Governments. Fresno COG supports this imperfect but necessary SIP and wishes to thank CARB staff for working ...↓

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Comment From: Fresno Council of Governments (Robert Phipps)

7/23/26 @ 3:26 PM Day of Board Meeting Form Letter 1

Madam Chair and Board members:
Thank you for the opportunity to speak. My name is Robert Phipps, executive director with Fresno Council of Governments. Fresno COG supports this imperfect but necessary SIP and wishes to thank CARB staff for working c...↓

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Comment From: Central California Environment... (Christian Bisher)

7/23/26 @ 1:17 PM Day of Board Meeting

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Comment From: Coalition for Clean Air et al. (Bill Magavern)

7/23/26 @ 1:11 PM Day of Board Meeting

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Comment From: Earthjustice (Adrian Martinez)

7/13/26 @ 4:46 PM 30-Day

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Comment From: Outdoor Power Equipment Instit... (Greg Knott)

7/13/26 @ 1:58 PM 30-Day

The Outdoor Power Equipment Institute (OPEI) respectfully submits the attached comments to the California Air Resources Board (CARB) regarding its 2026 State Implementation Plan Revisions for the California Extreme Ozone Nonattainment Areas (April 17...↓, 2026). OPEI requests that CARB review and update its Small Off-Road Engine (SORE) SORE2020 emissions model to accurately reflect the sector's baseline emissions and reductions forecasted by the 2022 State Implementation Plan (SIP). In the meantime, CARB should remove incorrect forecasted emissions reductions from the SIP. As evidenced by the examples provided herein, CARB's 2020 Emissions Model for Small Off-Road Engines – SORE2020 (SORE2020) and 2022 SIP grossly overestimates Small Off-Road Engine (SORE) emissions and reduction, especially in California's non-attainment areas like the South Coast Air Basin (SCAB).

OPEI has repeatedly expressed concerns that CARB SORE2020's emission model relies on inaccurate data and overestimates of the sector's baseline and forecasted exhaust gas and evaporative emissions. In its development of SORE2020 CARB ignored CSU-F cautions about using uncorrected and/or small sample size data. Furthermore CARB put its own data in question closing the SORE2020 report saying "the need for improvement of future data collection efforts of SORE activity and that accurate, real-world data may be obtained through the use of data logging instrumentation." Nevertheless, CARB continues to use the model to support and defend its SORE rulemaking, its related EPA wavier requests, and its 2022 State Implementation Plan, including SORE reductions forecasted for the South Coast Air Basin through 2037.

SORE2020's errors are plentiful and critical. These comments included just a handful of issues, examples and data-based resolutions. Errors extend beyond SORE lawn-and-garden applications. For example, assuming residential SORE-powered pressure washers run 29 hours per year is also unreasonable and results in mischaracterization of the products emissions footprint. OPEI continues to collect data to dispute bad assumptions, but data concerns raised by OPEI dating back to 2020 remain largely unresolved.

CARB should work to immediately correct the model and/or remove anticipated SORE emissions reductions from the 2022 SIP until a reasonable and stakeholder agreeable model is developed.

OPEI looks forward to collaborating with CARB's modeling team at the soonest possible convenience to address SORE2020's fatal flaws and unfair sector characterization.

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Comment From: Californians for Pesticide Ref... (Sarah Aird)

5/22/26 @ 11:48 PM 30-Day

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Comment From: Central California Environment... (Nayamin Martinez)

5/18/26 @ 8:45 PM 30-Day

Comments uploaded. Thank you

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Comment From: SoCalGas (Jessilyn Davis)

5/18/26 @ 6:22 PM 30-Day

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Comment From: Emily Marquez

5/18/26 @ 4:37 PM 30-Day

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Comment From: Western Propane Gas Associatio... (Krysta Wanner)

5/18/26 @ 3:02 PM 30-Day

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Comment From: Rinnai America Corporation (Perry McGuire)

5/18/26 @ 1:55 PM 30-Day

Please see attached comment letter.

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Comment From: Noritz America (Jay Hassel)

5/18/26 @ 1:35 PM 30-Day

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Comment From: Central Valley Air Quality Coa... (Catherine Garoupa)

5/18/26 @ 12:54 PM 30-Day

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Comment From: The Industry Coalition (CAA, C... (Robert Raymer)

5/18/26 @ 12:32 PM 30-Day

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Comment From: Brendan BURKE

5/14/26 @ 9:34 AM 30-Day

I am completely OPPOSED to any gas appliance ban now or in the future! Woke lies about safety and pollution abound, they are LIES.
Gas is good and power plants use it to generate electricity.
When electricity fails or is cut off gas provides heat,coo...↓

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Comment From: steven heath

4/27/26 @ 7:14 AM 30-Day

My name is Steven Heath, I am a commercial plumber, inventor, and student in environmental science.

I propose that the state update the RACT definition for the 'Consumer and Commercial Products' category to include vapor-lock barrier standards for c...↓

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